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California Regional Water Quality Control Board <br /> Central Valley Region <br /> Karl E. <br /> Longley,ScD,P.E.,Chair e�;a'�=='r� <br /> Linda S.Adams -611411020 Sun Center Drive#200,Rancho Cordova,California 95670Arnold <br /> Secretaryfor Phone(916)464-3291 •FAX(916)464-4645 Schwvernegger <br /> Environmental http://www.waterboards.ca.gov/centralvalley Governor <br /> Protection <br /> 22 June 2009 RECEIVEDMs. Claire Holtzapple <br /> U.S. Department of Energy JUN 2 4 2009 <br /> Livermore Site Office <br /> P.O. Box 808, L-293 ENVIRONMENTAL HEALTH <br /> Livermore, CA 94551-0808 DEPARTMENT <br /> DRAFT COMPLIANCE MONITORING PLAN AND CONTINGENCY PLAN, <br /> ENVIRONMENTAL RESTORATION DEPARTMENT, LAWRENCE LIVERMORE NATIONAL <br /> LABORATORY SITE 300, SAN JOAQUIN COUNTY <br /> The California Regional Water Quality Control Board, Central Valley Region (Central Valley <br /> Water Board) staff has reviewed the March 2009 Draft Compliance Monitoring Plan and <br /> Contingency Plan (CMP/CP) submitted on your behalf by Lawrence Livermore National <br /> Security, LLC. Please address the following comments in the final CMP/CP-- <br /> 1. <br /> MP/CP:1. Page Summ-2, first paragraph. DOE states "Detailed plans will be generated after the <br /> CMP/CP is finalized and modified periodically to reflect changing site conditions, new <br /> monitor and extraction wells, and stakeholder concerns." Please include where the <br /> detailed plans will be documented. <br /> 2. Page 4, Section 1.2. Site Description. DOE lists nine contaminants or groups of <br /> contaminants of concern (CDCs) at Site 300. After the nine bulleted CDCs, DOE states <br /> "Figure 1-3 shows the ground water contaminant plumes that have resulted from the <br /> releases of CDCs discussed above." Figure 1-3 shows groundwater plumes five of the <br /> COCs: volatile organic compounds (VOCs), high explosive compounds, perchlorate, <br /> tritium and depleted uranium. Discussions of individual Operable Units (OUs) in sections <br /> 1.2.1 through 1.2.10, discuss remedial actions for all of the COCs except metals. Add <br /> discussions of metals under the appropriate OU sections or, if metals are no longer <br /> considered COCs, remove them from the list. For example, Section 1.2.6. Building 854 <br /> (OU 6) states that metals were identified as COCs in surface soil but metals are not <br /> mentioned in the following discussion of remedial actions for Building 854. <br /> 3. Page 6, Section 1.2.2. Building 834 (OU-2). Although concentrations of nitrate have <br /> reduced from 749 milligrams per liter (mg/L) in 2000 to 310 mg/L in 2008, DOE states that <br /> continued elevated concentrations of nitrate indicate that an ongoing source of nitrate <br /> exists at Building 834. Please explain what mechanism is reducing nitrate concentrations, <br /> why DOE believes an ongoing source exists, and what that source is. <br /> California Environmental Protection Agency <br /> � Recycled Paper <br />